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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
United States of America v. (Johnson & Johnson) DePuy, Inc. · Johnson and Johnson's Involvement in Multiple Countries from 1998 to 2007

Case Information

United States of America v. (Johnson & Johnson) DePuy, Inc.

Related FCPA Matter:   Johnson and Johnson's Involvement in Multiple Countries from 1998 to 2007 Information

Case Information

Initiation Date:    01/14/2011  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    1:11-cr-00099

Court:    District of Columbia

Name of Prosecuting Attorneys:   

  • Paul E. Pelletier, Principal Deputy Chief, Fraud Section, Criminal Division
  • Kathleen M. Hamann, Trial Attorney, Fraud Section, Criminal Division

US Assisting Agencies:   

  • U.S. Securities and Exchange Commission
  • Federal Bureau of Investigation
  • Department of Justice - Criminal Division's Office of International Affairs

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:   

  • U.K. Serious Fraud Office (GB)
  • Athens Court of First Instance, 8th Ordinary Interrogation Department (GR)
  • Athens Economic Crime Squad (GR)
  • Polish Regional Prosecutor’s Office, 5th Investigation Department (PL)
  • Fraud Squad of the West Yorkshire Police Department (GB)

Origin of the Proceeding:    Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Johnson & Johnson (“J&J”) was incorporated in New Jersey and had its principal place of business in New Brunswick, New Jersey. It issued and maintained a class of publicly traded securities registered with the SEC, which traded on the New York Stock Exchange.

DePuy, Inc. (“DePuy”), a wholly owned subsidiary of J&J, together with related companies, was a global manufacturer and supplier of orthopedic medical devices. DePuy was incorporated and headquartered in Warsaw, Indiana, and maintained operations in a number of foreign countries.

From 1998 to 2006, DePuy, and various of its subsidiaries and employees, made payments of approximately $16.4 million in cash incentives to publicly employed Greek health care providers to induce the purchase of DePuy products. These payments were primarily made through several agents and local distributors in Greece.

On April 8, 2011, the DOJ filed a two count Information in the District of Columbia against DePuy alleging conspiracy to violate the anti-bribery and books & records provisions of the FCPA as well as direct and aiding and abetting violations of the anti-bribery provisions of the FCPA. On the same date, a Deferred Prosecution Agreement between J&J and the DOJ with a term of three years was filed in court. Under the terms of the DPA, J&J agreed to accept responsibility for the conduct of its subsidiaries, including DePuy and others, and agreed to pay a monetary fine of $21.4 million and to implement enhanced anti-corruption compliance policies and procedures, which included a requirement for J&J to issue periodic reports for three years to the DOJ on its anti-corruption compliance. On May 19, 2014, the court granted the government's motion to dismiss the DePuy Information based on J&J's compliance with the DPA.

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